Matter of Gonzalez, 24 I&N Dec. 549 (BIA 2008) (a single act of soliciting an act of prostitution on ones own behalf does not fall within INA 212(a)(2)(D)(ii), 8 U.S.C. 1182(a)(2)(D)(ii), where this case involved a disorderly conduct conviction relating to soliciting an act of prostitution).

Note: In California, prostitution is defined as sexual intercourse for a fee, while Penal Code 273(b) covers asking for, offering, or providing lewd conduct for a fee. Lewd conduct is more broadly defined than intercourse, and the statute is not divisible.

Matter of Montiel, 26 I&N Dec. 555 (BIA Apr. 17, 2015) (immigration judge has discretion to delay removal proceedings, where warranted, pending the adjudication of a direct appeal of a criminal conviction); following Matter of Avetisyan, 25 I&N Dec. 688 (BIA 2012).
Cal Crim Def 21.24, 20.28

Note: There is no logical reason why the immigration court does not also have discretion to postpone removal proceedings when other requests for post-conviction relief are pending.

Villanueva v. Holder, 784 F.3d 51 (1st Cir. Apr. 24, 2015) (Connecticut conviction for assault in the third degree, under Conn. Gen.Stat. 53a"61, did not constitute a crime of violence aggravated felony, under INA 101(a)(43)(F), 8 U.S.C. 1101(a)(43)(F), where the record of conviction did not indicate the subdivision under which the noncitizen was convicted, since two of the three sections involved only recklessness or negligence which are insufficient intent to constitute a crime of violence under 18 U.S.C. 16).

Arias-Minaya v. Holder, 779 F.3d 49 (1st Cir. Feb. 27, 2015) (immigration judge is not barred from considering police reports containing hearsay in determining whether noncitizen deserves relief as a matter of discretion, even where noncitizen was never convicted), citing Paredes"Urrestarazu v. INS, 36 F.3d 801, 810 (9th Cir.1994); Parcham v. INS, 769 F.2d 1001, 1005 (4th Cir.1985).